SUPPORTING STATEMENT
MANAGEMENT OFFICIAL INTERLOCKS
(OMB No. 3064-0118)
INTRODUCTION
The FDIC is requesting a three-year renewal of the currently approved collection of information captioned above. The clearance for the collection expires on October 31, 2007. There is no change in the method or substance of the collection.
A. JUSTIFICATION
1. Circumstances and Need
This collection is associated with the FDIC’s Management Official Interlocks regulation, 12 CFR 348, which implements the Depository Institutions Management Interlocks Act (DIMIA), 12 U.S.C. 3201-3208. DIMIA generally prohibits bank management officials from serving simultaneously with two unaffiliated depository institutions or their holding companies but allows the FDIC to grant exemptions in appropriate circumstances. Consistent with DIMIA, the FDIC’s Management Official Interlocks regulation has an application requirement at section 348.6 requiring information specified in the FDIC’s procedural regulation, 12 CFR 303.250. The rule also contains a notification requirement at section 348.4(i).
2. Use of the Information Collected
The information is used to provide state and federal examiners of depository institutions with documentation which will allow them to ascertain whether depository organizations are eligible for a management interlock exemption.
Use of Technology to Reduce Burden
Currently, the low number of respondents for this collection does not make conversion to electronic submission cost beneficial.
Effort to Identify Duplication
There is no duplication. Each situation is unique.
5. Minimizing the Burden on Small Entities
There is a small market share exemption under which qualified banks need not submit information that would otherwise be required. Note: The FDIC recently implemented an increase in the small bank exemption, from $20 million to $50 million, pursuant to a statutory mandate (the Financial Services Regulatory Relief Act of 2006). Because more banks will be covered by this exemption as a result of the change, the effect is to reduce burden overall. However, because banks must submit an application to be considered exempt, there is likely to be an increase in the number of respondents for this collection, with a concomitant upward adjustment in burden, as more small banks take advantage of the increased threshold for the exemption.
6. Consequence of Less Frequent Collections
This occasional collection is the minimum required to implement the statute.
7. Special Circumstances
None.
8. Summary of Public Comments
A “first” Federal Register notice seeking comment was published on August 29, 2007 (72 FR 49720). No comments were received.
9. Payment or Gift to Respondents
None.
10. Confidentiality
The Freedom of Information Act will govern the confidentiality accorded to the information in the collection.
Information of a Sensitive Nature
This requirement contains no sensitive information.
Estimates of Annualized Burden
Number of respondents: 6
Number of responses per respondent: 1
Total number of responses: 6
Hours per response: 4
Total hours: 24
Total Annual Cost Burden
None.
14. Annualized
Cost to the Federal Government
$1,440 (6 applications x 8 hours per review x $30 per hour).
15. Reason for Program Changes or Adjustments
The change in burden of +16 hours (from 8 hours to 24 hours) is an adjustment, the effect of an increase in the number of reporting institutions from 2 to 8.
16. Publication
No publication is made of the information.
17. Display of Expiration Date
Not applicable.
18. Exceptions to Certification
None.
STATISTICAL METHODS
Not applicable.
Attachments
1. Statutory mandate, 12 U.S.C. 3201-3208
2. Regulatory mandate, 12 CFR 348
3. “First” Federal Register notice; draft “second” Federal Register notice
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | FDIC |
| Last Modified By | shanft |
| File Modified | 2007-10-11 |
| File Created | 2007-10-11 |